Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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The ITAT dismissed the assessee's appeal, upholding the levy of penalty under s.271(1)(c) insofar as it relates to additions confirmed by the Tribunal; the assessee failed to demonstrate any error in the quantum of additions as upheld by CIT(A) and ITAT. The rectification under s.154 by DCIT, which granted carry-forward of past losses inadvertently omitted, did not constitute a computational mistake affecting the confirmed additions and therefore does not mitigate penalty exposure. Because no infirmity was shown in the appellate order, no recalibration of the penalty relative to the s.154 reduction was warranted and the impugned assessment and penalty stand affirmed.
The ITAT dismissed the assessee's appeal, upholding the levy of penalty under s.271(1)(c) insofar as it relates to additions confirmed by the Tribunal; the assessee failed to demonstrate any error in the quantum of additions as upheld by CIT(A) and ITAT. The rectification under s.154 by DCIT, which granted carry-forward of past losses inadvertently omitted, did not constitute a computational mistake affecting the confirmed additions and therefore does not mitigate penalty exposure. Because no infirmity was shown in the appellate order, no recalibration of the penalty relative to the s.154 reduction was warranted and the impugned assessment and penalty stand affirmed.
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